The Tennessee Walking Horse Breeders' and Exhibitors'Association (hereinafter referred to as "TWHBEA"), headquartered in Lewisburg, Tennessee, is the oldest and most prestigious organization devoted to the promotion of the breed. Founded in 1935, the breed registry was established to record the pedigrees of the Tennessee Walking Horse. lts goal is to maintain the purity of the breed, to promote greater awareness of the Tennessee Walking Horse and its qualities, to encourage expansion of the breed, and to help assure its general welfare.

TWHBEA has recorded more than 521,528 registered Tennessee Walking Horses for over 82,814 distinct individuals from all 50 states and 31 foreign countries, recorded over 1,500,000 ownership exchanges and maintains official records for the membership throughout the world.

The TWHBEA protects the investment of Tennessee Walking Horse owners by establishing policies and requirements, and maintaining the breed registry. A 12-person Executive Board, selected from the lnternational Board of Directors representing members in all 50 states and several foreign countries, plays the key role in establishing these policies. The success and popularity of the Tennessee Walking Horse is the result of thoughtful organization and strong leadership by the Tennessee Walking Horse Breeders' and Exhibitors'Association, and it is the essential organization for the continued success of the breed. The Executive Committee of TWHBEA voted Friday, February 19th, 2016 to unanimously approve Project Pegasus.

STATEMENT OF THE TWHBEA Dckt. No. APHT5-2011-0009

Project Pegasus

This venture invests with the Walking Horse Equine Federation to coordinate several world- renowned equine veterinarians and other nationally renowned experts to develop scientific, predictable, pre-show objective tests for the sole purpose of protecting the Tennessee Walking Horse and their exhibitors. The singular standard is the health of our horse. The goal of Project Pegasus is to preserve and protect our show horse for generations.

The Tennessee Walking Horse Breeders' and Exhibitors' Association, the oldest and most prestigious Walking Horse organization in the world, will lead this project with an initial investment of S125,000 donation made possible by the association, private donations, and contributions by all senior staff and Executive Committee members. The fund will be managed by the directors of the Tennessee Walking Horse Breeders' Foundation.

Project Pegasus has three objectives. The paramount goal will be to ensure that every Tennessee Walking Horse shown in competition is safe, sound, and healthy. The second goal will be to guarantee a scientifically objective, fair, predictable, and accurate pre-show inspection. A healthy and vibrant show circuit remains the final goal. As Vice President of TWHBEA, Nancy Lynn Greene states, "a healthy show circuit is not only vital but is directly related to the success of the breed."

The TWHBEA is the MOST SIGNIFICANT stakeholder, and most affected organization, REGARDING implementation or changes in the rules and regulations regarding the exhibiting of the Tennessee Walking Horse. The TWHBEA was not contacted in any way for information and input, nor were they involved in any discussions regarding the drafting of the above referenced proposed rule. After the rule had been prepared (the contents were unknown to the TWHBEA), a meeting was granted at the Office of lnformation and Regulatory Affairs with the TWHBEA representatives and a representative of the HIO supported and endorsed by the TWHBEA, the Walking Horse Equestrian Federation. At that time the individuals representing the Office of Information and

Regulatory Affairs would not divulge the content of the proposed rule or when the proposed rule might be available for review and comment, which placed the major stakeholder in a position of making comments on subject matter on which they had obtained information only through rumor and innuendo. Therefore, any meaningful dialogue by the major stakeholder did not take place prior to the drafting of the proposed rule, nor have they been given the opportunity to provide appropriate input and information which is critical in rulemaking decisions.

The TWHBEA is opposed to the proposed rule in that there has not been adequate input, analysis, scientific evidence, or information obtained from impartial, non-conflicted professional organizations, nor the appropriate stakeholders of the industry, Further, there is a historic basis for an appropriate alternative to this arbitrary and capricious rulemaking, both in practice and by Presidential Executive Order:

During the tenure of James S. Gilliland, General Counsel for the Department of Agriculture, the cooperation and dialogue regarding the application of the Horse Protection Act reached the highest level of effectiveness during the HPA era.

One major contributing factor was General Counsel Gilliland's instructions to then APHIS Director, Terry Medley, to establish an External Review Committee to examine objective and impartial measures to evaluate what could be done to improve procedures and report their findings and recommendations to the USDA for action to improve the enforcement of the HPA.

This same philosophy should be utilized at this time as a cost effective, more efficient and unquestioned probability of successful results.

All parties agree that the intent and purpose of the Horse Protection Act has not been effectively accomplished in over 45 years. The subjective nature of the attempts to enforce the HPA has led to agenda-driven bias and has destroyed any semblance of a working relationship between the industry and the USDA. The unequivocal fact is that inspections are unreliable as a result of personal subjectivity on the part of the inspector and failure to utilize objective standards.

The current inspection process is not working. Rulemaking would be contentious, counterproductive and has historically led to litigation.

This concept is confirmed in several Presidential documents, including Circular A-4, September 17,2003, and Executive Order 13610, May 1-0, 20L2. Quoting from EO L3610 signed by President Obama:

". . .To the extent practicable and permitted by law, agencies shall also give special consideration to initiatives that would reduce unjustified regulatory burdens or simplify or harmonize regulatory requirements imposed." And further, give priority to reforms that would make significant progress in reducing those burdens"

These comments are being respectfully submitted for consideration in opposition to the current rule and the process utilized. Scientific evidence has been ignored and a reasonable, far superior alternative has been developed which would result in an objective, scientific based process conducted by non-conflicted and non-agenda driven personnel. The best result, both legally and procedurally, is to discuss and analyze available scientific information before rulemaking.

It is the TWHBEA's steadfast position, that in light of the historic precedence of the USDA's failure to obtain appropriate and scientific information, and based upon Executive Order quoted above that:

The Rulemaking should be abandoned and specifically A committee should be formed comprised of non-conflicted, non-agenda driven equine veterinarian experts to review, analyze and develop scientifically based, objective inspection protocols which comply with the intent of the Horse Protection Act, eliminate the subjectivity of show inspections, and place the welfare of the horse at the forefront.

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